This legal summary discusses the appeal filed by Rathi Steel & Power Ltd against the penalty imposed by the Assessing Officer for failure to issue TDS certificates on time, under section 272A(2)(g) of the Income Tax Act, pertaining to the assessment year 2014-15. The case was filed on February 24, 2021, with the final tribunal order pronounced on August 4, 2022.
The Assessing Officer noted that Rathi Steel & Power Ltd failed to issue the required TDS certificates within the prescribed timeline, resulting in a penalty of Rs.11,84,599. The appeal was first taken to the Commissioner of Income Tax Appeals, who dismissed the case, prompting further appeal to the Income Tax Appellate Tribunal.
The appellant, represented by Ms. Supriya Mehta, argued that the penalty was unjust due to reasonable cause and that there was no revenue loss as the TDS was deposited timely. The tribunal acknowledged procedural lapses in the CIT(A)’s decision, particularly the failure to grant an adjournment requested on legitimate grounds and not deciding on the merits of the case.
The tribunal set aside the CIT(A)’s order and remanded the case back for re-adjudication, emphasizing the need for a fair hearing and adherence to the principles of natural justice.
This case highlights the implications of administrative lapses and the importance of procedural justice in tax appeal matters. The tribunal’s decision to remand the case back for a comprehensive review underlines the necessity of considering all factual circumstances and legal arguments before rendering a decision.
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